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J�Rco stp� . <br /> AIra UNITED STATES ENVIRONMENTAL PROTECTION AGENCY <br /> REGION IX <br /> sir 75 Hawthorne Street <br /> San Francisco, CA 94105 <br /> JUN 0 4 2004 <br /> May 26, 2004 rNV;'r)UMNI I HEALTH <br /> PIMNIITiSEhVICES <br /> Mr. Marshall Cloud <br /> Defense Distribution Depot San Joaquin California, Tracy Site <br /> DDJC-FA, Attn: Environmental Management <br /> P.O. Box 960001 <br /> Stockton, CA 95296 <br /> Re: Review of the Response to Comments (submitted May 19, 2004 <br /> electronically) on the Draft Final Explanation of Significant Differences <br /> (ESD) to the Site-Wide Comprehensive Record of Decision,Defense <br /> Distribution Depot San Joaquin (DDJC) Tracy Site, Tracy, California, April <br /> 2004 <br /> Dear Mr. Cloud: <br /> The U.S. Environmental Protection Agency (EPA) Region 9 has received the Response to <br /> Comments (submitted May 19, 2004 electronically) on the Draft Final Explanation of Significant <br /> Differences (ESD) to the Site-Wide Comprehensive Record of Decision, Defense Distribution <br /> Depot San Joaquin (DDJC)Tracy Site, Tracy, California, dated April 1, 2004. <br /> It appears that all except one of EPA's comments on the Draft Final ESD have been <br /> addressed in the preliminary Response to Comments (RTC) table distributed electronically on <br /> May 19, 2004. The exception is noted below. It should also be noted that the RTC table was <br /> issued after the submittal of the Draft Final ESD document. Some of the RTCs include language <br /> that explains that the text will be modified accordingly. Therefore, the upcoming Final ESD will <br /> need to be reviewed along with the RTC table included in the Final ESD to verify incorporation <br /> of the requested modifications. <br /> GENERAL COMMENT <br /> 1. Response to New General Comment 2: The response states that the comparison <br /> between DDT and DDX will be retained. This is acceptable, however further <br /> clarification is requested to show that the residual DDT does pose an unacceptable health <br /> risk. Table 4-3, Page 4-5 under Risk to Human Health from DDT states that 47 <br /> micrograms per kilogram (ug/kg) is the maximum residual DDT left in place. It then <br /> discusses the Record of Decision (ROD) risk-based concentration for DDX. A direct <br /> comparison between the DDT and DDX cannot be made. It would be helpful to the <br /> reader if the 47 ug/kg of DDT was presented with its associated risk assessment (a cancer <br />